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Talk to a SpecialistTalk to a SpecialistThe Vapor Club LLC was warned that its e-liquid products are regulated tobacco products under FDA jurisdiction because they contain nicotine from any source, and the company failed to obtain required premarket authorization orders before marketing them in the United States. The FDA determined that these products are subject to compliance with the Federal Food, Drug, and Cosmetic Act and its implementing regulations, which mandate that "new tobacco products" must have FDA premarket approval before being legally distributed. The company's apparent violation involved selling and distributing e-liquid products without securing the necessary marketing authorization orders required under section 910 of the FD&C Act.